In previous posts I discussed the annual limit waiver process for mini-med plans as well as the upcoming MLR rules regarding mini-med plans. Today, OCIIO amended the annual limit waiver application process for mini-med plans, including adding a participant notice requirement. This notice is yet to be posted to the website, but it is required to be sent to participants in a plan that has obtained an annual limit waiver. OCIIO also announced its intention to provide a special methodology for mini-med plans to better satisfy the upcoming MLR rules. The special methodology is expected to be available for at least the first year the MLR rules are effective. As noted in a prior post, the MLR rules only apply to insured mini-med plans. The updated guidance is linked as follows:
http://www.hhs.gov/ociio/regulations/11-05-2010annual_limits_waiver_bulletin.pdfDisclaimer
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.
